1. Introduction, definitions and Scope
1.1 This policy has been prepared to defines the procedures for the treatment of such inactive/ dormant accounts.
1.2 Definition of Dormant Accounts or Inactive account: An account is considered dormant o inactive if there have been no transactions initiated by the account holder for a period of 12 (twelve) months. This includes savings accounts, current accounts, and other types of bank deposits.
1.3 The term “Inactive account”/”Dormant account” refers to such trading account/depository client wherein no trades or no debit transaction have been carried out since last 12 (Twelve) months across all Exchanges.
1.4 This policy is applicable to all Rintral Trading Depository Participant Client accounts.
2. Monitoring
2.1 The AML/KYC Compliance team monitors client accounts to check for any inactive/dormant account on a regular basis and to ensure compliance with the laid down policies.
2.2 The verification of the inactive/dormant accounts in the system is done on a monthly basis by end of the calendar month as per the procedures mentioned below.
3.1 Procedure for deactivation of dormant accounts
3.1.1. Identification of Inactive Accounts: The AML/KYC Compliance team generate a list of all accounts that have shown no activity for the last 12 months.
3.1.2. Classification: The AML/KYC Compliance team classifies these accounts as Inactive/Dormant Accounts and forward the list to the Operations team for further action.
3.1.3. Deactivation: The Operations team deactivate the identified accounts in the system and update the status of these client codes in the database of the exchange.
3.1.4. Settlement of Accounts: Upon identification of an account as inactive, the client’s funds and Dormant account are settled in the presence of the AML/KYC Compliance team. The settlement process will adhere to the periodicity (monthly/quarterly) chosen by the client, and all assets (funds, securities, or other collateral) shall be returned to the client. A statement detailing this settlement must be sent to the client.
3.1.5. Continued Reporting: The Operations team continue to send all usual client reports for deactivated accounts.
3.2 Procedure for reactivation of Dormant Accounts
3.2.1. Client Request: If a client wishes to trade or transfer securities or funds from/to their account, and the account has been deactivated due to dormancy, the client must submit a formal request for reactivation via our customer support channels (e-mail or creating a ticket in the CRM).
3.2.2. Verification: The AML/KYC Compliance team verifies the identity and credentials of the client.
This includes:
- Confirming the client's identity using current KYC documentation.
- Verifying the client's request through a registered contact method (e.g., phone, email).
3.2.3. Documentation: The client must provide any updated KYC documents if required. The AML/KYC Compliance team shall ensure all documentation is current and valid.
3.2.4. Approval: Once verification and documentation are complete, the AML/KYC Compliance team approves the reactivation request.
3.2.5. Reactivation Process: The Operations team oversees:
- Reactivate the client's account in the system.
- Update the client’s status in the database of the exchange.
- Notify the client of the reactivation via email or other agreed communication channels.
3.2.6. Post-Reactivation: The client is informed that their account is now active and they may proceed with trading or transferring securities or funds.
3.2.7. Record Keeping: All requests, verifications, and communications regarding the reactivation process are being documented and retained for compliance and audit purposes.
3.3 Inactive Account Fee
3.3.1. Monthly Inactive Account Fee: When an account becomes inactive, a monthly inactive account fee will be charged. An account maintenance and fund custody fee is charged for the upkeep of the account and safekeeping of the funds deposited therein.
This fee will continue to be charged until the account is reactivated or funds are insufficient to cover the fee.
3.3.2. Amount: If a user's trading account remains inactive for 12 consecutive months, the platform applies a monthly maintenance fee of 4 euros until activity resumes and the balance is reset. Following this, the account is temporarily suspended
3.3.3. Notification: The fee charge will be duly notified to the client through the communication methods accepted by them.
3.3.4. Abandoned Accounts: If there has been no deposit, withdrawal, or other contact from you for 12 consecutive months, your account will be considered abandoned. In accordance with the law, funds from abandoned accounts will be reported and disbursed appropriately.
3.3.5. Account Statements: Inactive accounts will receive only one annual statement.
3.4 Procedure for communicating the present policy to clients
3.4.1. Terms and conditions: This policy is part of the terms and conditions that must be accepted by clients when contracting products.
3.4.2. Client Confirmation: For all existing clients, the update of the existing terms and conditions of the contract is sent through the communication channel agreed with the client, including the modification represented by this policy.
Once notified, accordingly with Spanish regulation 16/2009, customers will have a period of 2 (two) months to communicate their disagreement with this policy,
which will mean the cancelation all of their accounts and their closure.
This policy ensures proper management of inactive accounts and compliance with legal requirements regarding abandoned funds.